>> Good afternoon. I'm Kristyn Pompa
Guth with PT, today's webinar is on
CTPAT Forced Labor. You'll be on mute
during the presentation, we ask you
submit questions you have in the CHAT
feature. I'd like to pass it over to
Felicia Pullam.>>
All right. My name is Felicia Pullam.
I'm the executive director of trade
relations at CTP.>>
In December, January to be national
human trafficking prevention week. This
is our second, national human traffic
prevention. And a lot has happened
since the first one.This
is a priority issue for the bide Anne
administration for DHS and for CTP.
Almost 28 women, men and children are
forced globally. The [Background
Noise].Went
into effect of June 2022. CTP has been
working very hard for implementation
law. Forced Labor is a major challenge
for all of us. And we understand that
many companies and many other
organizations are working very hard on
this area. We understand that-- thank
you. For everybody who showed up today.
Thank you for sharing your time with
us. Thank you for your effort on Forced
Labor and thank you for your interest in
CTPAT which is a very important program
that makes our country safer.So
we are really glad that so many people
are here today. And we will share
information that's useful and enables
you to get more involved.If
you want to learn more of DHS's
campaign, you can check out DHS.gov/--
type in campaign--You
can also visit CTP website. We hope to
see you at the 2023 summit, scheduled
for April 17 through 19 in Boston. So
keep a look out for more information
coming out on that, soon. I'd like to
internal it over to our CTPAT Director,
Manuel Garza.>>
All right. Thank you so much for that,
and Kris Krys from OTR helping us out on
this wonderful webinar today.I
know there was a little bit of audio
with XD but can everybody hear mine
okay? All right. I'm seeing much
better. All right. Thank you very
much.So
Forced Labor is a big topic. You heard
yesterday from the office of trade and
the Forced Labor force division. Today
you'll here about CTPAT. We have two
programs. We have our security program
and trade compliance program.Security
is what everybody is responsible for.
That's in CTPAT. Compliance is only for
our U.S. importers. So I want to make
that clear as we talk about the
requirements for the program as they
revolve around Forced Labor that
everybody understands there are two
programs. Security is what everybody
has to follow and trade compliance is
for importers that are part of trade
compliance.Next
s slide, please.So
for those of you, I know we have a
little over 900 is the last count I saw
participants in this presentation here.
We have about 11,000 partners that are
part of our CTPAT security program. And
we have just a little under 300 in our
trade compliance program. So quite a
big difference between the two. And
trade compliance is really considered a
huge benefit for those, you know, 300
plus companies that are part of
it.Security,
everybody knows that it's, is you know,
not only do we focus on Forced Labor,
but it encompasses everything from
cybersecurity, agricultural security,
seal security, human resources,
container inspections. Where trade
compliance is really-- goes in a
different direction and focused on the
company providing CBP information and
monitoring their own compliance.
That's really the big difference. On
the security side, CTPAT goes out and
does the validations on the trade
compliance side, importers are
responsible for conducting
self-assessments.Next
slide, please.So
for those of you that participate in the
summit over the summer of 2022 in
Anaheim, you may have heard Carmen Perez
and Amy talk about the mandatory Forced
Labor requirements that we're coming to
the CTPAT trade compliance program.So
they became mandatory August 1. And
I'll go into details on what those
requirements are. But August 1, it
became a mandatory for brand new
applicants into trait compliance.
Again, this is only for trade compliance
partners. I'll talk security in a few
minutes.New
applicants, and this is brand new
companies applying for new compliance
within CTPAT must meet the requirements
at time of application. That's a really
big, important thing that we want to
make sure that everybody understands is
that, if you are a new company that is
applying to the trade compliance program
today, you must meet those
requirements.If
you are already an existing trade
compliance partner, your requirements
are not due until you have one year from
August, 1, 2022. So August 1, 2023ment
your program requirements are not
required until your annual notification
letter which is due after August 1,
2023. I want to be clear that for new
applicants, it's due now. For existing
partners and trade compliance, you have
until 2023, August 1, 2023 to have them
implemented and available.Next
slide, please.Yeah,
you can go to the next slide. I just
talked about that, I'm sorry.>>
On the CT CT, on the security side,
minimum security criteria 3.9 and can I
apologize this slide is a little old. I
should say it's 27 days old. But
minimum security criteria 3.9 is CTPAT
partners must, that should, is no longer
there. It is now a must.So
for those of you that are importers,
those of you who are manufacturers and
those of you who are exporters in the
CTPAT program, the minimum security
criteria, 3.9 has changed. And it is
now CTPAT partners must have a
documented social compliance, program in
place. So we are going to publish that.
It will be part of the, our updated
booklets that we post. I don't know
that we'll be able to change it in our
CTPAT portal just yet. We're
undergoing changes to the portal.And
you know, so we're actually, we're
developing a Newport al to they're
really limiting the development pieces
of the existing one. It will a part of
the new, portal within the security
profile of the new, portal. Again,
criteria 3.9 for CTPAT partners must.
So when we do share this, we will make
sure that we get you an updated slide
for this one because it is a must. And
I don't want to cause any confusion out
there.Next
slide, please.*.
So what are the Forced Labor
requirements? We have six new Forced
Labor requirements that the CTPAT
program worked in conjunction with the
Advisory Committee for the last, I would
say three and a half to four years.
We've been working diligently on what
these Forced Labor requirements would
look like. And these are the six.
We're looking at risk based business
mapping. Something that companies
already do today. You're already
mapping at your business partners and
you're identifying risk. Code of
conduct, that is something that-- code
of conduct specifically on Forced Labor,
social compliance.We'll
be looking at evidence of
implementation. We'll be looking at
due diligence and training. We're
going to require a remediation plan,
that you have something in place so
that, when a business entity of yours or
a business partner of yours is
identified to be sourcing from, with
Forced Labor or has forced labor in one
of their facilities, what are you going
to do about it? That's our remediation
plan.And
finally we're going to ask that you
share best practices as a business
partner. Best practices must be, they
need to be something that we can share,
right? Things that we want to make sure
that the rest of the trade in
understand, hey, this is what business
partner is doing, or this is how they're
making this work. Or these are some of
the things that they're using to elevate
their practice to the next level so that
it helps and keeps forced labor out of
their particular supply chain.Next
slide, please.So
risk based mapping. Partners are
required to conduct risk based mapping
of their businesses. Companies should
determine within their organization what
imports are considered high risk. For
those of you on the security side, I
know we've gone through this many times,
me as a supply chain specialist in years
past. Companies would always ask me,
Manuel, what constitutes high risk
andAnd
we said it then, I'll say it faux, high
risk is for you as a company to decide
and determine what is high risk.
Because high risk for you may mean
something completely different for
someone else. The idea is that you are
looking at a risk within your business
model. And that companies, you know,
can understand.And
so when CTPAT does the evaluation, we
can say, okay, you do have a risk
process in place. And a commitment
should be made in include in the code of
conduct. And CBP will likely be asking
for evidence of your supply chain
mapping. So things that you guys all do
today for trade compliance, when the
national account manager is doing the
report and reviewing all the
documentation, this is something that
they'll be looking for.Again,
current business-- current applicants
will have to have this in place. And 16
partners will have to make sure that
this is available after August 1,
2023.Next
slide.Code
of conduct. Partners must create a code
of conduct statement that represents
their position against the use of forced
labor within any part of their supply
chain.So
when we were putting this together, we
talked to a number of companies that
were in the code act. Almost everybody
that that we speak to was in CTPAT. *
and every single one of them already has
some type of code of conduct that
identifies the use of forced labor
within their supply chain.So
this one right here is probably one of
the easiest requirements of the program.
Most of you already have this listed on
your websites. If you don't, we're not
telling you how long it has to be, how
short it has to be. As long as you are
indicating that you, as a company, do
not adhere to the use of forced labor
within the supply chain, that you are
not going to accept that.The
code of conduct, the code of conduct
statement must be uploaded to the portal
and published by you, the partner for
the program.Next
slide, please.So
if you're in the CTPAT program already,
there's no reason you shouldn't be aware
of this. But evidence of
implementation, that has already been a
requirement, you know, for a number of
years in regards to the minimum security
criteriamentS
as we go out and collect the
validations, we tell you, you need to
show us how you implemented that policy.
There's nothing different about it on
trade compliance. It's the same thing.
You're going to have to show us
evidence of implementation of your
social compliance program. Right?So
there should be-- that should not come
as a shock to anybody. Evidence can be
videos. It can be training information.
It can be tests that you guys conduct.
Any audits that you all conduct, et
cetera, et cetera.You
know, examples of evidence may include
unredacted audits, training, et
cetera.Next
slide, please.And
like I mentioned before, training, you
know, that is also of utmost important.
It's most importantly-- it's most
important so your business partners
understand this as well. And that they
should be conducting their own training,
you know, to make sure that this is not
happening. And it's not -- it doesn't
have to be 100% of the employees need to
be trained on this. Again, this is all
part of your risk. You identify where
the risk is. You identify who needs to
be trained within the program, the
people that are handling the HR side of
it, maybe the people actually doing the
work, the job of building the widgets,
whatever it is that they're making in
the factories. Those are the people you
need to get the information out to
them.And
of course, the last bullet there says
that suppliers' business model and code
of conduct states that they will not
partner with any businesses that use
forced labor. It's important. Right?
It's not just for each of you. It's for
your business partners as well to say,
hey, we're not going to accept, we're
not going to stand for forced labor
within our supply chain.Next
slide, please.So
I mentioned earlier, the remediation
plan, partners must maintain a
remediation plan for their organization
in the event that forced labor is
identified in their supply chains. Part
of the plan must include the process for
disclosing the identification to CBP and
outlining the necessary steps for the
organization's employees and suppliers
to undertake and correct the issue.I
will tell you that, and we're going to
get to benefits. Everybody's going,
what's in it for me? We'll talk about
benefits in a few minutes here. But I
want you to understand that a this is
extremely important that you have a plan
in place that you notify CBP whether
you're notifying your national account
manager for trade compliance partners.
You're notifying, compliance email box.
You're notifying the Forced Labor email
box. There's lots of companies that you
can, there are lots of resources, I'm
sorry, that you can reach out to within
CBP please keep that as part of your
note know remediation plan so there are
no issues.We
understand this. This is a big issue.
We've talked about it with senior
leadership within CBP with nor he is
over the phone and the office of trade
and even our acting commissioner Troy
Miller is familiar with the desire for
companies to want to provide information
but at the same time, you know, not get
in trouble for providing that
information.So
we are working very hard at trying to
identify some way that partners in
CTPAT, trade compliance, CTPAT security
can provide information to CBP without
penalty at thises or having shipment
stopped and things like that. * it's
not a prior disclosure because that's
very specific. But we're trying to
identify something similar to that so
partners are not worried about
disclosing that information.Next
slide, please.And
best practices and path forward. The
key thing to making, not making sure,
but to help others have good strategies,
a good way to do things is by sharing
best practices. Sharing best practices
with not only your national account
manager or your supply chain security
specialists, to me, to many Carmen, to *
the oughts of trade, Forced Labor
division. When it comes to forced
labor, Nick you think as a business
partner you think is doing great, we
want to make sure that we can get that
information * out to the public so that
they can implement potentially similar
processes.You
know, it's not just about one company
doing great. It's about all of us
trying to do as much as we can to
eradicate forced labor from the supply
chain.Next
slide, please.And
so I mentioned that there were some
benefits to this program. And we have
identified three that he have with
already established. And we have
already provided to the trade.So
November of last year, November, 2022,
you know, we published a document with
the new benefits for trade compliance
partners, specifically this is for trade
compliance partners. And the first one
is pridization review of admissibility
packages submitted for forced labor
deexpr its.So
companies that are submitting their
documents to the ports * and to the
centers are having theirs moved up to
the front of the line for review. So
that's a-- I mean, that's not an easy
lift because these packages are no way
easy reviews. But it definitely does
help you as a CTPAT compliance partner
to get your shipment closer to seether
being released or having a * decision
made instead of I waiting pour however
Hong period of time you have to wait
for, two months, three months. It can
take a while for the admissibility
completion.Redelivery
holds. So what we identified with this
was that CTPAT trade compliance partners
have had shipments arrive at their
facility. And we will allow those
shipments to be, if they're already
there at your facility and then we
identify that there's an issue with
them, we will allow them to stay intact
at the facility.So
this is a benefit so that you're not
having to redeliver the goods for
physical inspection. Okay? Until the
admissibility determination is made.
So, you know, it helps especially if
there's no physical inspection that's
required and admissibility determination
is made that it can stay in the U.S. So
really strong benefit for partners.Next
slide, please.And
for shipments that are detained at the
border, subject of a WRO, we are
allowing shipments to move to bonded
facilities. So straight compliance
partners who have shipments detained due
to the WROs will be allowed to move
them to the bonded facility held intact
in the a an as missability determination
is made by CBP.Again,
your detention gets to go to a bonded
facility. Your shipment is going to be
able to get expedite the review for
admissibility claims and move a lot
faster. So that's what we have in store
for CTPAT trade compliance.Next
slide, please.I
think that's the slides.So
I know we've got a lot of questions that
have been coming in. And I've got my
team who is going to present any
questions to me. Carmen, did I miss
anything before we get into the
questions?>>
Carmen: No, sirment I couldn't have
done it better myself.>>
*>>
Manuel Garza: Thank you. So we'll turn
it over to the questions.>>
The first one-- okay. I think one--
it's not a question. But Teresa is
joining at 2:45 to answer any specific
Forced Labor questions. The first
question is, at what pointed is the
zip-- required at entry, crossing or
transmission? In the entry summary?>>
Manuel Garza: I don't have that answer.
We can get back.>>
Okay. Do you want to do the last one or
continue?>>
My apologies. I didn't hit the unmute
button quick enough. We have another
question that just came in. Is there a
cost to become a CTPAT member?>>
Manuel Garza: Is there a cost? Well,
there's no fee. The CTPAT program does
not charge a fee for the program.
Either security or trade compliance,
there are class associated with
developing your CTPAT program especially
if you don't have policies in place
already. So you would need time to
develop policies and procedures.You
have to look at all the eligibility
requirements. You have to look at all
the minimum security criteria. You can
do all of that prior to applying to the
program. You know, there's a lot of
physical security components that are
required. So you may have to take a
look at your facility, and is it
properly securitied? Do you have doors
that are locked? Do you have lights and
cameras? Do you employee employ
security guards? * there's a lot of *
things that you have to do before.I
think everybody on the line that is
CTPAT partner can tell you, there's no
fee. There definitely is a cost to
participating in the program.
thank you for that Kate.>>
Thank you, sir. I'll just jump in with
another one. We've been seeing a few
questions regarding some of the dates
for implementation. So maybe could we
clarify that a little bit specifically
there's been questions regarding the
portal change after 8-1, 23. And how
the forces labor * requirements will be
included in the annual reporting.>>
Manuel Garza: Okay, so August 1, 2022,
new companies that are applying to trade
compliance must * provide their
information on the six items, the six
requirements for Forced Labor for trade
compliance.So
brand new companies applying after
August 1, 2022 must provide that
information at the time of application.
The existing partners are not required
to provide that information until their
annual notification letter that is due
after August 1, 2023.CTPAT
security partners mandatory requirement
went into effect for companies that must
have a social compliance program in
place went into effect January 1, 2023.
Again, that a loo iz to importers,
manufacturers, * and exporters of the
program.>>The
CTPAT portal. Let me clarify that. On
the security side, the security profile
of a partner will only, will still say a
"should." It will not change until the
Newport al is released in June of this
year.Once
the Newport al is released and the new
security profile * is updated, partners
will have to make those changes in the
security profile. That does not exempt
you, if you have a validation that's due
in March or if we do a validation in
March of this year, that does not exempt
you from not having the policies in
place.If
you're a brand new partner applying to
the CTPAT trade compliance program, as
of August 1, 2022 you must include those
six requirements into your
application.If
you are an existing trade compliance
partner, you have to submit requirements
with why you are annual notification
letter package that is due after August
1, 2023.So
if your A and L is due in February of 23
if, you don't have to include the
information on Forced Labor. If you're
ANL is due in November * of 2023, then
yes, you must include your-- the Forced
Labor requirements within that AN. L.
And on the security side, * validations
taking place in 2023, they'll be looking
to make sure that companies have
implemented the Forced Labor
requirements for importers, exporters,
and for manufacturers.Ing
again, * it won't be available in the
security profile module in the portal in
had mid to late June of this year.Next
question.>>
Will the slides be available on the
CTPAT website?>>
Manuel Garza: Yes, ma'am, they will.>>
Okay. Let's see. Another question. Can
you expound on the confidentiality
regarding the remediation plan?>>
Manuel Garza: Um, confidentiality, in
terms of remediation, if you were to
notify the CBP, anybody within CBP with
potential, if you identified a forced
labor within your supply chain, we
don't have a benefit in place for that
yet. We are working to develop
something.And
as soon as we get it developed, we're
working with the office of trade. We're
working with the office of chief
counsel. And as senior leadership has
expressed an interest in us providing
some type of benefit for the partners
that provide information to CBP about
forced labor within the supply chain.>>
One other one, is the program open to
new applicants?>>
Manuel Garza yes, ma'am, as of August 1,
2022, the trade compliance * program has
opened for new importer applicants. And
the CTPAT security program has been-- is
currently available for new applicants
as well.>>
Okay, here's another one that came in.
Can you please qualify whether movement
of goods bonded facility is permitted
willful deexpr its or WRO detentions?
If it's just permitted for WRO, can you
advise what are the other benefits are
for CTPAT trade compliance. Prioritized
review or redelivery hold are also
limited to WRO?>>
Manuel Garza: Um, it's a complicated
answer. We'll provide a more feedback
later.>>
Thank you. We did get a question
regarding benefits and the question is:
Would one be kicked out of CTPAT if they
did not report any Forced Labor found?>>
* can you repeat the question?>>
The question is, would one be kicked out
of CTPAT if they did not report any
forced labor that was found?>>
Manuel Garza: Would you be kicked out?
So if forced labor is identified within
your supply chain, and you knew about it
and you didn't notify us, would you be
kicked out?It's
too general of a statement. I think
we'd have to look at all the
circumstances just as we do with our
current removal process for security and
for trade compliance.But
in a nutshell, I don't think you will be
kicked out for not reporting. But if
you do know, it would behoove you to
make us aware of a forced labor issue
and that you're addressing it.The
idea is that, we want good business
partners. And you're a good business
partner, you're going to gain a lot more
respect from CBP by informing us of some
of the concerns or some of the issues
you've seen or identified. And we can
work with you.The
example I'll use is trucks carrying
drugs across the border. If the
business partner is notifying us that,
hey, my truck driver went off route
didn't go the way he was supposed to.
He's not responding to my phone calls,
please inspect him. And we inspect him
and we find drugs.The
likelihood of getting suspended is very
low. You're telling us because you
identify it as part of your risk
assessment and your monitoring services
that there was an issue. And it worked.
And it paid off.It
the driver shows up and says, hey, I got
pulled over on the side of the road, I
don't know what they did to the back of
the truck. Make sure you send me to
examination for inspection. We're
probably not going to do anything.
We're probably going to, you know, be
very grateful.We'll
do an investigation just to see what
could we as a program do to help? What
can the company do to put themselves in
a better posture. But you're telling
us. You're providing that
information.And
so we want to be able to do that with
forced labor. We want to be able to
tell you, thank you for telling us about
it. Now, let's move forward. and get
there.>>
Next question?>>
About the security profile. Should it be
updated by the anniversary or by June
2023?>>
Manuel Garza: So we'll send out
notifications of what needs to be done
with the peoplation of the new, portal
as we get closer. Implementation *>>
Okay.There's
some that I think would be best if-- was
going to join because they're
specifically on the way of Forced Labor
prevention act. Here's one.Director
Garza on the webinar yesterday they
advise all shipments detain can be moved
to a bonded warehouse, can you reconfirm
this. As you discussed today your
November 2022 letter advised the CTPAT
compliance program benefit was having
the ability to move goods detained based
on a-- is this benefit open to all?>>
Manuel Garza: Like I said earlier, it
really is for the WROs at this point.
We are still evaluating where we should
open it up to all or not.>>
And this question, I can answer. Do
tier three existing partners
automatically become trait compliance
partner?No,
not automatically. You have to apply to
the program. Correct?>>
Manuel Garza: Correct.>>
I don't see another-- oh, here. Most
exciting CTPAT have evidence of full
implementation or just a good start
especially if a large importer with a
complex supply chain.>>
Manuel Garza: So for security, does an
importer have to have full
implementation of the Forced Labor
requirement?>>
Must an existing-- must an existing
CTPAT have a full implementation, or a
good start for a large importer with a
large supply chain.>>
Manuel Garza: Again it should be based
on risk that they should be focused on.
And if risk means 100% for the company,
then yes, it needs to be 100%. If risk
is 20% for the company, it should be 20%
risk that they identify.>>
And do I only update the six requirements
or do I have to resubmit the entire
security profile?>>
Manuel Garza: So I any they're
confused. The six requirements are for
the trade compliance partners. And they
will get that. Six requirements are not
for the CTPAT security. CTPAT security,
there's just one criteria that has
changed from a should to a must.>>
Okay. Could you please clarify detained
shipment or detained only when bonded
warehouse or this is where I thought you
were going something to FT. A's
conditional release, too.>>
Manuel Garza: I'm not sure I understand
the complete question here.>>
Let me-- can you please clarify-- for
detained shipments, are they detained
only, detain only going to the bonded
warehouse or something to similar to
what conditional, what's going on with
FDA-- *.>>
Manuel Garza: No. These are only--
[Speakers Overlapping] no, this is only
on the WRO shipments at this time.>>
For current CTPAT member, we have the
Forced Labor requirements in place,
should we update our portal now or wait
until August 2023?>>
If you have them already, by all means,
feel free to update them.>>
Okay. We're trying-- what constitutes
due diligence to validate suppliers?
a supplier's sub supplier are compliant
and how often must this level of audit
be performed?>>
Manuel Garza: Yeah, again, it's based
on risk. So as you identify your risk
are, whether it's your tier one
supplier, tier two, tier three, those
are what you need to identify as a
business partner, risk. What Forced
Labor doesn't stop at the first tier.
Forced labor continues on. * so
identifying, you know, okay, this sector
within the supply chain, maybe you don't
need to worry about a certain part that
you have. But maybe there's another
thing that you should be concerned
about.So
that's all about identifying risk. And,
uh, and that's the extent, I think, that
you should be going. Do I think
anybody's going to be able to do 100% of
their supply chain from scratch? I
don't think so. But we want you guys to
focus on your risk.>>
I'm sorry. So staying on the topic of
risk, we have another question that is
from a freight forwarder. All these
questions seem directed to be importers
as a CTPAT freight forwarder, do you
have practical suggestions to require
with the requirements>>
Unless you're acting as an importer,
these are not applicable to you.>>
And that was moves on, we got questions
regarding, we did get another question
that asks, if we are a security member
and cannot many a trade compliance
member, will our detention reviews also
be given some sort of priority?>>
Manuel Garza currently right now * the
trade compliance partners are the ones
receiving the benefit.>>
Let's see. There's some questions. We
have quite a few questions on Forced
Laborment we're going to hold off on
those until-- comes by to handle
those.We
did get a couple of questions, going
back to the basics of what the
difference is with a trade compliance
and the security partner just in the
beginning of the presentation.>>
Manuel Garza: I'll start with security.
CTPAT security we have 13 different
entities that a are currently able to
apply to the CTPAT program. Customs
brokers, freight forwarders, air
carriers, rail carriers, highway
carriers, long all carriers, U.S.
importers, exporters, et cetera. Those
are the current security partners in the
program.For
importers, exporters, and the
manufacturers, 9 for manufacturers
located currently-- we only have
manufacturers in Mexico and Canada.
Those are * all required under the
security criteria 3.9 that was recently
changed from a should to a must. Those
partners must have a social compliance
policy in place that's security
side.Trade
compliance is an additional tier or an
additional program within CTPAT. And it
is only for importers.It's
formally called the importer's
self-assessment program, ISA. It's been
moved under the CTPAT program. And it
is now our CTPAT trade compliance
program. With the trade compliance, the
partner is responsible for submitting an
annual review to CBP.On
the security side, we do them every four
years, and the supply chain specialist
is the one who goes out and conducts a
validation visit. Trade compliance,
like I said, they submit their
documentation after they did their own
review, their own audit of their
company. And this is for compliance
related to entries and imports.They
do their audit. And our national
account managers, our import specialist
whys review the documented submitted *
and it comes to our Headquarters, trade
compliance, whereby we do the final of
those letters. Those are about the two
differences in the programs.>>
Thank you. I'm sorry. I believe that--
[Speakers Overlapping].>>
Special advisorrer now to CBP is on.
I'm going to go back to the question from
the beginning regarding today's CSMS
message regarding if CBP updates amid--
postal code that is subject to the labor
pores, labor prevention act, how will
the I am porter be notified to the
postal code other than the WRO?>>
Can you say that again?>>
Okay. I'm sorry. [Speakers
Overlapping]>>
Would you like to introduce yourself
first before I ask the question?>>
I'm happy, too. I'm having an issue with
video here. A here we go. Yeah, hi,
everybody I'm Theresa. I'm special
advisor to the Forced Labor division in
the office of headquarters.>>
This one it was regarding a CSMS message.
If CBP updates amid versus CMSMS
message including a postal code-- how
would the importer be notified of the
change through the postal code other
than the WRO?>>
the question, there's no WRO involved
here because the postal code is under--
shipments coming from the region of
China and subject to the labor labor
prevention act. There's no WRO involved
here.the
in terms of the notification to the
importer that a postal code has been
changed-- I will have to get back to you
on that because I have not been closely
involved in the development of the
postal code, how that's going to work.I
know there's a lot of position on the
trade support network related to that.
But I have to take that question back.>>
Okay. If the company's going through
risk and analysis survey assessment, how
will they be grandfathered into CTPAT
compliance? Maybe that's not for you.
But for Manny, sorry.>>
Manuel Garza: Can you repeat the
question, please>>
If a company is going through a RASA,
will they be grandfathered into CTPAT
compliance?>>
I don't know what they mean by
grandfathered in. They will still be
required. If they applied and going
through the process, then I don't
believe that they would have had to
submit their documentation because that
might have been ongoing for sometime
now.I
don't believe any of the new applicants
are going to RASOs right now. * but at
the time, once they're certified, trade
compliance, for their next cycle, they
will be required to provide the
information on the six requirements.>>
I will say, I'm sorry to interrupt.
There was, and I don't know if the
confusion might be-- there's a
historical benefit on a focused
assessment into the trade compliance
program, formerly importer assessment
program.We
have not yet gotten rid of that benefit.
Of so the focus assessment or focus
assessment into trade compliance. So
that could be maybe a little bit of the
confusion also. So that's still around
per right now in case that's what
somebody may be thinking.>>
Okay, I'm looking for more Ms.
Radazzo.When
will the postal code application be
enforced?>>
It starts on March.>>
Randazzo * *>>
Will there be a list provided of the--
[inaudible]. Is that what's going to
be-- post al code affected.>>
In all of this, all of the postal codes
are covered-- it will be covered.
There's not going to be change to them.
There's not a list of them specifically.
It's all of them.>>
Okay. I don't see any more-- Kate, do
you see any more?>>
Related to that, I did want to go back,
a couple of questions regarding the
benefits for WRO in detention. We
announced the benefits back in November.
And we've been getting questions about
the, one of the questions was, can we
clarify whether the movement of goods
for bonds-- if it's just for WRO, can
you advise whether the other benefits
for trade compliance is also limited to
WRO? There's been confusion, I think,
regarding the benefits.>>
Manuel Garza: I think I had already
clarified that particular one.
Currently it's for WRO only. We are
still evaluating whether it will be
implemented for that.>>
Okay, here's another one for Theresa.
When will the importer be notified that
had the shipment will be detained for
use postal code in the ISF documentation
filing?>>
So the notification would be at entry.
At-- the postal code requirements is part
of release. So you will be notified at
that time that there's, the postal code
goes back to location in the-- and if
you decide to enter the goods anyway,
then they will all be detained because--
are excluded immediately because it's
subject to immediate exclusion.>>
Where is the list of the subject postal
code?>>
It's all in the post at code in the zing
Giang. *>>
I don't believe I have any more for you.
Was there anything else that I
missed?>>
I think we're running into our last
couple of minutes. We did have one
question regarding Forced Labor's, how
are I am shoulds selected for compliance
for Forced Labor? That mighting a broad
question and we're getting tight on
time, I think.>>
So is this a general question about how
we select shipments for-->>
Yes, ma'am.>>
For-- for potential forced labor
concerns? And so we select shipments
based on the intelligence and
information that we have available. We
work to identify the highest risk
shipments based on the available
information.And
then those shipments are targeted. I
guess that's the short form answer I can
give with limited time here.>>
Thank you. I think that's it. I mean,
we have one minute left, if there's any
other questions or comments coming in,
please put them in the CHAT box.>>
Thank you, everyone. This concludes our
webinar for this afternoon. Please keep
in mind that registration will be coming
out soon for the trade facilitation,
April 17 through 19. Thank you for
your day.>>